Taxation-Federal Commons^™

The Transaction Test For Federal Income Tax Loss Deductions

Washington and Lee Law Review

No abstract provided.

Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr.

William & Mary Law Review

No abstract provided.

An Analysis Of The Taxation Of Stock Dividends From 1918 To 1970; Effects Of The Tax Reform Act Of 1969 On § 305 Of The Internal Revenue Code, Harvey J. Eger

Duquesne Law Review

On December 10, 1969, the most massive and controversial piece of tax legislation ever proposed was enacted by Congress. One small portion of this act, § 421, has substantially altered the tax status of stock dividends by amending § 305 of the Internal Revenue Code of 1954. As a result, § 305 now covers a wide variety of situations where the receipt of stock dividends previously nontaxable will give rise to income taxable at ordinary rates.

Federal Income Taxation--Scholarship And Fellowship Grants--Validation Of Treasury Regulation, Leslie C. Smith

Kentucky Law Journal

No abstract provided.

Federal Income Tax - Casualty Loss Deduction - Determining The Proper Basis Figure In A Partial Casualty Loss To A Timber Tract - What Is The Single, Idnetifiable Property Damaged Or Destroyed, The Trees Or The Entire Tract?, John W. Bell

Loyola University Chicago Law Journal

No abstract provided.

Federal Taxation And Non-Profit Organizations, Marcus Schoenfeld

Cleveland State Law Review

The Revenue Act of 1969 is one of the greatest overall changes in the revenue laws since the introduction of the federal income tax . Perhaps the most extensive changes were made in the area of tax-exempt organizations. Only some of these changes were within of the topic of this presentation, and some of the other changes in the "charitable" area merit great discussion-for example charitable remainder trusts. Even the topics discussed herein, of necessity were discussed briefly due to lack of time and Regulations. The full the 1969 Act on non-profit organizations will not be apparent for quite some …

The Not-For-Profit Business Corporation, James K. Weeks

Cleveland State Law Review

The Non-Profit Corporation is usually regarded traditionally from a lay and legal viewpoint as one being engaged in charitable, educational, scientific or social work or a religious endeavor. On the other hand, the Not-for-Profit Corporation is more often engaged in enterprises usually associated with functions of a business corporation. However, as soon as one begins to view these corporations from a definitional standpoint, one is bogged down in an incredibly complicated procedure which does little to clarify the confusion.

Taxation—Stipends Given In Conjunction With Employer Doctoral Programs Are Taxable As Compensation For Employment, A. Bruce Norton

Buffalo Law Review

Bingler v. Johnson, 394 U.S. 741 (1969).

Taxation- Deductibility Of Contributions To Segregated Private School

University of Richmond Law Review

Brown v. Board of Education set the stage for an extensive series of activities designed to circumvent the Court's intention to abolish segregated public education. However legally futile many of these endeavors have become, there remains one instrument of education over which the fourteenth amendment is powerless: the private school. Since tuition alone inevitably fails to generate sufficient revenue to fund the necessary expenses of construction and operation, private charitable contributions are needed, and are encouraged by their deductibility for federal income, as well as estate and gift tax purposes.

Recent Legislation

University of Richmond Law Review

This is a list of the recent legislation from 1970.

Personal Vs. Business Expenses: A Comment On Professor Klein's Approach, William D. Popkin

Articles by Maurer Faculty

No abstract provided.

Tax Significance Of Payments In Satisfaction Of Liabilities Arising Under Section 16(B) Of The Securities Exchange Act Of 1934, Lawrence Lokken

Scholarly Works

This article examines the income tax significance to the insider of his payment in satisfaction of a liability arising under section 16(b). Such taxpayers have usually sought a deduction against ordinary income in the year of payment. When the issue was first raised, the deduction was denied. Section 16(b) liability was held to be in the nature of a penalty; allowance of the deduction, it was found, "would weaken an effective method of enforcing the sharply defined policy expressed in sectin 16(b)...." In 1961 the Internal Revenue Service modified its earlier position by ruling that section 16(b) is not a …

Recent Developments In The Audit Program Of Federal Tax Returns, Singleton B. Wolfe

William & Mary Annual Tax Conference

No abstract provided.

Mandatory Buy-Out Agreements For Stock Of Closely Held Corporations, Douglas A. Kahn

Articles

A buy-out of a shareholder's stock is a sale of his stock holdings in a specific corporation pursuatnt to a pre-existing contract. In recent years such arrangements have, deservedly, become an increasingly popular planning device for shareholders in closely held corporations; they make it possible to limit the class of potential shareholders, provide liquidity for the estate of a deceased shareholder, and establish a value for stock which has no active market. There are two popular categories of buy-out plans. If the prospective purchaser of a decedent's shares is the corporation that issued them, the plan is called an "entity …

Taxation—Kimbell-Diamond Still Available As An Adjunct To Section 334(B)(2)., Harry Sushek

Buffalo Law Review

American Potash and Chemical Corp. v. United States, 399 F.2d 194 (Ct. Cl. 1968).

Taxation—Tax Avoidance Need Only Be One Of The Purposes For Imposition Of The Accumulated Earnings Tax, Jerome M. Hesch

Buffalo Law Review

United States v. The Donruss Company, 393 U.S. 297 (1969).

Tax Planning For The Not-So-Rich: Variable And Private Annuities, Anthony M. Vernava

William & Mary Law Review

No abstract provided.

Book Notes, Law Review Staff

Vanderbilt Law Review

The Child Savers: The Invention of Delinquency By Anthony M. Platt Chicago: University of Chicago Press, 1969. Pp. ix, 202.$8.50.

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Juvenile Delinquency and Urban Areas (rev. ed.) By Clifford R.Shaw & Henry D. McKay Chicago: University of Chicago Press,1969. Pp. 394.

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The Positive School of Criminology Edited by Stanley E. Grupp Pittsburgh: University of Pittsburgh Press, 1968. Pp. vi, 114. $5.95.

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State and Local Tax Problems Edited by Harry L. Johnson Knoxville: University of Tennessee Press, 1969. Pp. xiii, 190. $7.50.

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Tension in the Cities By James A. Bayton Philadelphia: Chilton Book Co., 1969. Pp. x, …

Income Tax: Corporate Distribution--Tax Benefit Rule Does Not Qualify The Explicit Nonrecognition Of Gain Provision Of Section 337--Anders V. Commissioner, Michigan Law Review

Michigan Law Review

D. B. Anders was the sole stockholder of D. B. Anders, Inc., an industrial service concern which rented supplies of laundered apparel, coveralls, towels, and related textiles. In May 1961, the corporation adopted a plan of complete liquidation and within twelve months sold substantially all of its operating assets, including the rental items, to another corporation which intended to carry on the same type of business. Of the gain from that sale, $233,000 was allocated to the rental items, the entire cost of which had been deducted by the company in the year of purchase as an ordinary and necessary …

Federal Taxation - Accumulated Earnings Tax - The Quantum Of Tax Avoidance Purpose Required - United States V. Donruss, 89 S. Ct. 501 (1969), Robert S. Parker Jr.

William & Mary Law Review

No abstract provided.

Federal Taxation - Professional Service Corporation - Corporate Versus Partnership Statute - Empey V. United States, __ F. 2d __ (10th Cir. 1969)., Haldane Robert Mayer

William & Mary Law Review

No abstract provided.

Non-Business Guaranty Loss: Ordinary Or Capital Deduction, Robert S. Parker Jr.

William & Mary Law Review

No abstract provided.

Excessive Salaries In A Closely Held Corporation, Donald J. Zinner

Cleveland State Law Review

Excessive salaries paid by a closely held corporation create a constant debate between the "owners" of the entity and the Internal Revenue Service, and with other corporation members. The basic law as to the tax aspects underlying the controversy, in the Internal Revenue Code of 1954, is substantially as follows: The compensation claimed as a deduction must be reasonable in amount, and must be paid purely for services. Distributions of profits under the guise of salaries are not deductible. This crucial issue leads to the question: What does the word reasonable salary mean in the framework of a closely held …

Retirement Plans Limited To Salaried Employees: Tax Advantages And Qualification, Gerrit C. Kuechle

Cleveland State Law Review

Retirement plans are among the most effective tax saving devices available and can be extremely attractive, as will be shown, to the small corporation and the highly compensated employee, especially when it is considered that a properly designed plan can be integrated with Social Security so that larger benefits are provided on the salary in excess of that covered by Social Security than on the salary subject to Social Security.

Retirement Plans For Self-Employed Individuals, Doris R. Hauth

Cleveland State Law Review

The self-employed individual has not yet gained the status of the corporate employee in his ability to defer income, but the Keogh Act, asamended in 1967, does afford him substantial tax savings. The benefits should be thoroughly considered by all who qualify.

Administration Of A Negative Income Tax, William D. Popkin

Articles by Maurer Faculty

No abstract provided.

Tax Status Of Educational Grants, James P. Boyle

William & Mary Annual Tax Conference

No abstract provided.

Professional And Educational Expenses, John E. Donaldson

William & Mary Annual Tax Conference

No abstract provided.

H.R. 10 - Plans And Problems, Emeric Fischer

William & Mary Annual Tax Conference

No abstract provided.

Book Review Of Items Of Gross Income, Emeric Fischer

William & Mary Law Review

No abstract provided.